The following Starr companies and branches have a presence in the UK and are covered by the below tax strategy:
- Starr Managing Agents Limited
- Starr Underwriting Agents Limited
- Starr Syndicate Ltd
- Starr International (Europe) Limited
- Starr Insurance & Reinsurance Company Limited (UK Branch)
- Starr Europe Insurance Limited (UK Branch)
Together, the above entities are referred to as “Starr UK”.
This tax strategy describes Starr UK’s approach to conducting its tax affairs and managing its tax risks, in accordance with Starr UK’s obligation under Schedule 19 of the Finance Act 2016 (UK). The tax strategy has been updated for the 2020 financial year.
References to “tax” are to the taxes and duties set out in paragraph 15 of Schedule 19 which includes: Income Tax; Corporation Tax; Value Added Tax; PAYE; National Insurance Contributions; Diverted Profits Tax; Insurance Premium Tax; and Stamp Duty Land & Reserve Taxes.
Starr UK is comprised of those UK companies and operations that are part of one of the world’s leading insurance and investment groups, and trade under the worldwide marketing name of “Starr Companies”. Starr UK’s objective is to create long-term value for the Starr Companies group by providing high-quality and specialty insurance solutions to our clients. As part of this mission, we at Starr UK strive to be a responsible corporate citizen and a good employer within the UK community.
Our business activities generate a substantial amount and variety of taxes. We are subject to and pay corporation tax, employment taxes and other taxes. In addition, we collect and pay employee taxes as well as indirect taxes such as VAT and insurance premium taxes. The taxes we pay and collect form a significant part of our economic contribution to the UK.
Starr UK is committed to complying with the relevant tax laws in a responsible manner and to having open and constructive relationships with tax authorities in all the jurisdictions in which the business operates.
In June 2020, Starr UK appointed a Head of Tax to join their UK Finance team. The Head of Tax reports to Starr UK’s Finance Director and the Group Head of Tax.
Starr UK’s core values set out what is expected of everyone at Starr UK, and our approach to tax compliance and strategy aligns with those core tenets. Our commitment is underpinned by the following principles:
1. Our attitude to Tax planning
Starr is committed to complying fully with all applicable tax laws, rules and regulations, without exception.
Consistent with prudent business and financial management, we evaluate and engage in efficient tax planning that supports our business and commercial activity. We adhere to a general principle from Starr Companies’ Group Head of Tax that directly reflects our senior management view on the matter: business and commercial activities are to be the driving force of our business decisions and then we consider financial, tax, and accounting considerations. We do not engage in artificial tax arrangements in which the impetus for the transaction is its tax consequences. We adhere to relevant tax law and we seek to minimize the risk of uncertainty or tax disputes as part of our tax compliance process. We conduct transactions between Starr Companies’ members on an arm’s-length basis and in accordance with current OECD principles and relevant UK tax laws, including any applicable tax treaties.
We at Starr UK recognize that tax incentives and exemptions are sometimes implemented by governments and fiscal authorities in order to support investment, employment and economic development. Where these incentives exist we seek to apply them in the manner intended, but we do not intend to “arbitrage” the tax laws in a manner that yields a result contrary to the economic purpose of a business decision or transaction. We have, for example, established entities in jurisdictions suitable to hold our overseas business and trading operations, giving due consideration to our business activities and the prevailing insurance and business regulatory environment. Furthermore, we are not seeking to take advantage of any of the Covid-19 tax concessions put forward by various jurisdictions in which Starr UK operates as we are of the view that Starr UK is not the intended beneficiary of these incentives.
2. How we work with HMRC and other tax authorities
We seek to build and sustain relationships with HMRC and other tax authorities that are constructive and based on mutual respect. Starr UK proactively provides overviews of the business and strategy to our Customer Compliance Manager (CCM) at HMRC. We are open and honest in all our communication, and endeavour to pre-empt any tax issues, and consult on our interpretation of the law. Starr UK is committed to complying with our statutory obligations and the OECD principles.
3. Our approach to Transparency
We support the principle behind multilateral moves towards greater transparency that increase understanding of tax systems and build public trust. Starr UK operates in the insurance industry, and, as such, we have been accustomed to the concept of transparency in our financial reports and our dealings with tax authorities. We believe that this mind set is naturally adopted as part of our tax compliance and strategic efforts.
4. How we manage Tax risk and how much UK tax risk we are prepared to accept
We follow Starr UK’s risk management system as part of our entire internal control processes. Consistent with that approach, we identify, assess and manage tax risks and account for them appropriately, in accordance with relevant accounting standards. We implement risk management measures including controls over tax compliance processes and monitor their effectiveness on a quarterly/annual basis as appropriate. We report on a periodic basis to the Starr UK Boards on how tax risks are managed, monitored and assured and on improvements that are being made. In this way the Boards provide governance and oversight of tax risks.
Starr UK is committed to preventing persons associated with it from engaging in criminal facilitation of tax evasion and, where possible, has procedures in place to identify and mitigate the risk of facilitating such tax evasion.
Starr UK has retained Grant Thornton, TMF and RSM as tax advisors to assist with ongoing tax compliance as well as new developments. Any material changes to Starr UK’s operations will be discussed with our Tax Advisors.
5. Our approach to Tax Governance
The Starr UK Finance Director owns and implements our approach to tax which is approved and monitored by the Starr UK Boards. The Starr UK Finance Director is supported by Starr UK’s Head of Tax. The Starr UK Finance Director is also responsible for ensuring that policies and procedures that support the approach are in place, maintained and used consistently around the world, and that the UK Finance team has the skills and experience to implement the approach appropriately. The Starr UK Finance Director and Head of Tax report, on tax matters, to the Group Head of Tax who provides support and guidance as required along with the Tax Advisors mentioned above.